When a parent who has sole physical custody under an existing judicial custody order seeks to relocate, does the court have to determine that the custodial parent's relocation is necessary?

Although Burgess involved an initial determination of custody, we held that "the same conclusion applies when a parent who has sole physical custody under an existing judicial custody order seeks to relocate: the custodial parent ... bears no burden of demonstrating that the move is `necessary.'" (Burgess, supra, 13 Cal.4th at p. 37, 51 Cal.Rptr.2d 444, 913 P.2d 473.) But we recognized that, as with any allegation that "changed circumstances" warrant a modification of an existing custody order, the noncustodial parent has a substantial burden to show that "`some significant change in circumstances indicates that a different arrangement would be in the child's best interest.' [Citation.]" (Burgess, supra, 13 Cal.4th at p. 38, 51 Cal.Rptr.2d 444, 913 P.2d 473.) The changed circumstance rule provides "that once it has been established that a particular custodial arrangement is in the best interests of the child, the court need not reexamine that question. Instead, it should preserve the established mode of custody unless some significant change in circumstances indicates that a different arrangement would be in the child's best interest. The rule thus fosters the dual goals of judicial economy and protecting stable custody arrangements. [Citations.]" (Burchard v. Garay (1986) 42 Cal.3d 531, 535, 229 Cal.Rptr. 800, 724 P.2d 486.)³ "In a `move-away' case, a change of custody is not justified simply because the custodial parent has chosen, for any sound good faith reason, to

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reside in a different location, but only if, as a result of relocation with that parent, the child will suffer detriment rendering it `"essential or expedient for the welfare of the child that there be a change."' [Citation.]" (Burgess, supra, 13 Cal.4th at p. 38, 51 Cal.Rptr.2d 444, 913 P.2d 473.)

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